Primary Holding

The Supreme Court ruled that the accused should only be charged with simple rebellion, as established in People v. Hernandez (1956), and that rebellion cannot be complexed with other common crimes like murder, arson, and robbery. The Court upheld the doctrine that when common crimes are committed in furtherance of rebellion, they are absorbed into the crime of rebellion itself.

Background

The accused, high-ranking members of the Communist Party of the Philippines (CPP) and its armed wing, the Hukbong Mapagpalaya ng Bayan (HMB), were charged with rebellion for engaging in armed attacks, raids, and assassinations aimed at overthrowing the government. The trial court found them guilty of rebellion with multiple murders, arsons, and robberies, sentencing several to death or life imprisonment. On appeal, the Supreme Court re-evaluated the conviction under established jurisprudence.

Facts

• 1. The accused were leaders or members of the CPP and HMB, groups seeking to overthrow the Philippine government.
• 2. May 6, 1946 – Ambush of government forces in Nueva Ecija.
• 3. August 6, 1946 – Raid on Majayjay, Laguna’s municipal hall.
• 4. April 28, 1949 – Assassination of Aurora Quezon (widow of former President Quezon) and her convoy.
• 5. August 25, 1950 – Large-scale attack on Camp Macabulos, Tarlac.
• 6. The accused allegedly directed or participated in these activities, but they challenged their convictions, arguing that the government could not charge them with rebellion complexed with common crimes.

Arguments of the Petitioners

• 1. They argued that they could not be charged with rebellion complexed with murder, arson, and robbery as these crimes were part of the rebellion itself.
• 2. They challenged the admissibility of evidence, arguing that some documents were obtained illegally or burned before they could be re-examined.
• 3. They claimed lack of due process, stating that they were not given enough time to prepare their defense.

Arguments of the Respondents

• 1. The government argued that the accused committed heinous crimes distinct from rebellion, justifying the complex charge of rebellion with multiple murders, arsons, and robberies.
• 2. The prosecution maintained that even if the Hernandez ruling applied, the sheer brutality and scope of their crimes warranted separate penalties.
• 3. The Solicitor General requested the reexamination of the Hernandez doctrine, advocating for stricter penalties in rebellion cases.

Issues

• 1. Can rebellion be complexed with other crimes such as murder, arson, and robbery?
• 2. Did the trial court err in convicting the accused under a complex crime instead of simple rebellion?
• 3. Were the accused afforded due process and fair trial?

Ruling

• 1. The Supreme Court affirmed the ruling in People v. Hernandez, stating that rebellion absorbs common crimes committed in its furtherance.
• 2. The accused should only be charged with simple rebellion, not rebellion complexed with other crimes.
• 3. However, the Court ruled that the trial was fair, dismissing the accused’s claim of due process violations.
• 4. All sentences of death and reclusion perpetua were reduced to penalties applicable for simple rebellion.

Doctrines

• 1. People v. Hernandez (1956): Rebellion cannot be complexed with other common crimes.
• 2. Political Crime Doctrine: When a common crime (e.g., murder) is committed in pursuit of a political objective, it is absorbed by the political crime (e.g., rebellion).
• 3. Doctrine of Pro Reo: In case of doubt, the law must be interpreted in favor of the accused.

Key Excerpts

• 1. "The courts must apply the policy of the State as set forth in its laws, regardless of the wisdom thereof."
• 2. "Political crimes are those directly aimed against the political order, as well as such common crimes as may be committed to achieve a political purpose."

Precedents Cited

• 1. People v. Hernandez (1956) – The controlling precedent holding that rebellion cannot be complexed with common crimes.
• 2. People v. Geronimo (1956) – Reinforced the Hernandez doctrine, stating that acts of violence are absorbed by rebellion.
• 3. People v. Aquino (1960) – Confirmed that killings in furtherance of rebellion are not separate crimes but part of rebellion.

Statutory and Constitutional Provisions

• 1. RPC Article 134 – Defines rebellion.
• 2. RPC Article 135 – Prescribes penalties for rebellion.
• 3. RPC Article 136 – Conspiracy to commit rebellion.
• 4. RPC Article 48 – Complex crimes (which was ruled inapplicable).